The Tribunal ruled that the first appellate authority lacks power to dismiss appeals solely for non-prosecution. Appeals must be decided on merits with reasoned findings.
The Tribunal held that reassessment proceedings initiated after the statutory limitation period were invalid. Following the Supreme Courts ruling on reassessment timelines, the entire reopening and resulting additions were quashed.
The Tribunal held that an addition based solely on third-party search material without corroboration is unsustainable. With payments proved through banking channels, the cash allegation failed.
The Tribunal examined whether a creditor’s unilateral write-off automatically results in cessation of liability for the assessee. It held that such write-off requires factual verification and cannot, by itself, trigger addition under section 41(1).
The ruling clarified that exemption under section 54F cannot be denied if it was not part of the reasons for reopening. Reassessment was quashed as the sole addition lay outside recorded grounds.
Recognising the role of a Kaccha Arhtia, the Tribunal ruled that only commission constitutes income. TDS deducted on gross receipts belonging to farmers still entitles the agent to full credit.
Clear routes for eligibility, capital requirements, and fit-and-proper standards are prescribed. The key outcome is a more resilient and credible MF ecosystem.
The Tribunal examined whether a large consultancy payment was allowable when the assessee failed to establish its genuineness and business necessity. It upheld the disallowance, holding that mere claims without credible evidence cannot justify deduction of professional expenses.
The assessing authority made a large addition without explaining its nature or legal basis. The Tribunal ruled that such a cryptic order cannot stand and set aside the addition.
The Tribunal observed that the transfer pricing adjustment was based on unexplained margin calculations. A fresh working was directed to ensure accurate benchmarking of international transactions.
